Introduction

This policy sets out how we collect, process and hold your personal data if you enable one of our Alexa Skill or Google Action or otherwise provide personal data to us. We are Opearlo Limited of 7 Dumont Road, London, N16 0NR, United Kingdom. We are the data controller of your personal data.

This policy affects your legal rights and obligations so please read it carefully. If you have any questions, please contact us by email.

If you do not agree to this Privacy Policy, do not provide personal data to us.

Personal data we collect

In order to enable many of our voice apps, you do not need to provide us with any personal data. However, you may be offered the opportunity to provide us with a name, email address, geographical address and payment details. For our Find My Phone UK Voice App, you must provide us with your mobile phone number. If you choose to pay a fee to us to unlock features of the Voice App, we may receive your name, email address, geographical address.

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you..

Marketing Communications

You can subscribe to receive marketing communications from us by giving us your email address . Once we have received your email address, we shall send an email to you so that you can confirm your consent. We retain evidence of the details of your consent.

You can choose to no longer receive marketing communications by contacting us or clicking unsubscribe from a marketing email. If you do unsubscribe to marketing communications, it may take up to 5 business days for your new preferences to take effect. We shall therefore retain your email address in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.

Lawful processing of your personal data

We shall use your personal data in order to fulfill our contractual obligations to you, in particular to enable you to access and use the Alexa Skill or Google Action, to notify you about changes to this Privacy Policy and our Terms of Use and to provide you with requested information in response from an enquiry from you.

In addition, for our legitimate interests, we shall use your personal data to enforce our Privacy Policy and our Terms of Use, and for regulatory, legal purposes and audit purposes.

Who do we share your data with?

We may share your personal data with third parties for our legitimate interests.

We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, email service providers, accountants, auditors and lawyers. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

Under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, to protect a third party’s rights, property, or safety.

For our legitimate interests, we may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the EEA or if any of our service providers or their staff are based outside of the EEA. We shall only transfer your personal data to organisations that have provided adequate safeguards in respect of your personal data.

Security

We shall process your personal data in a manner that ensures appropriate security of your personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. All information you provide to us is stored on our secure servers.

However, you acknowledge that no system can be completely secure. Therefore, although we take these steps to secure your personal data, we do not promise that your personal data will always remain completely secure.

Your rights

You have a number of rights under applicable laws.

You have the right to access data that we hold about you, the right to correct and update data that we hold about you, the right to have your data erased, the right to object to processing of your data, the right to ask us to stop contacting you for marketing purposes, the right to request that we transfer your data to another controller and the right to object to automated decision making and/or profiling.

To exercise these rights, or any other rights you may have under applicable laws, please contact us. We shall confirm when we have carried out your request.

Please note, we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive.

If you have any complaints in relation to this policy or otherwise in relation to our processing of your personal data, please contact us. You can also contact the UK supervisory authority: the Information Commissioner, see www.ico.org.uk. If you are outside of the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

Retention

If you have enabled the Alexa Skill or Google Action and provided personal data to us, we shall retain your personal data until you notify us that you have disabled the Alexa Skill or Google Action.

If you have otherwise contacted us, we shall retain your data for 6 months from the date of contact.

If you receive marketing communications from us, we shall retain your personal data until you opt out of receiving such communications.

General

If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

This policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.

We may change the terms of this policy from time to time. We will try to give 30 days' notice of when changes take effect, by email and/or in your account if applicable, except where changes do not materially adversely affect you or are beneficial. If you continue to use our website after the time we state the changes will take effect, you will have accepted the changes.

Last updated May 2018

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